Further written evidence from the Chief
Fire Officers Association (CFOA) (MCA 19a)|
1. CFOA is the professional voice of the UK Fire
and Rescue Service (FRS), supporting its members to fulfil their
leadership role in protecting our local communities and making
life safer through improved service delivery. CFOA provides professional
advice to inform Government policy and is committed to developing
both strategic and technical guidance and sharing notable practice
within the wider FRS.
2. Membership of the Association comprises almost
all the senior management of FRS in the United Kingdom. CFOA is
the driving force in managing change and implementing reforms
in the Service.
3. CFOA has previously provided written evidence
relating to the Maritime Incident Response Group (MIRG) for the
Transport Select Committee (TSC) inquiry held on 8 February 2011.
4. The attached submission will expand on and
make reference to the initial evidence to inform the new inquiry
that is to be conducted by the TSC into the Coastguard, Emergency
Towing Vessels and the Maritime Incident Response Group.
5. In 2010,
the Maritime and Coastguard Agency (MCA) commissioned an independent
"Review of Requirements in Relation to Assisting with
Incidents Involving Fire, Chemical Hazards and Industrial Accidents
at Sea" (MCA Consultancy Project Ref CO96).
6. This review
was undertaken at a direct cost to the MCA of £81.9K by BMT
Isis Ltd and concluded in October 2010 in the form of a 233 page
7. The report
is underpinned by an assessment of risk around the whole of the
UK coastline and proposes a reasonable worst case scenario that
would involve "a passenger vessel fire that potentially needs
to be controlled for up to two days, has the potential to cause
loss of life and cannot be contained by the ship's finite resources".
8. The primary
aim regarding passenger ship emergencies is to maintain the integrity
of the ship so that the ship does not have to be evacuated at
sea. Large passenger ship design is regulated by the International
Maritime Organisation (IMO). A review of passenger ship safety
by the IMO has determined that such ships should be so designed
that fires or flooding should be contained by means of sub-division;
and that the ship should remain upright so that she can reach
a place of safety with her passengers and crew safe aboard.
9. While the
intention is that the ship should be so designed and equipped
and her crew so trained that she should be able to deal with fires
aboard from her own resources until she reaches port, the IMO
have also recognised the need for external support.
10. The IMO's
Maritime Safety Committee (MSC) published a Circular in 2006,
"Guidelines on the provision of external support as an
aid to incident containment for Search And Rescue authorities
and others concerned" (MSC.1/Circ.1183). The Circular
lists, inter alia, "fire-fighting personnel and equipment"
as its prime example of such support:
of shore-based fire-fighters, suitably trained and equipped for
incidents at sea, may be brought to the ship in distress by helicopter
and/or by surface craft, to advise and assist the ship's crew
in tackling and/or containing fires, smoke, and/or chemical hazards
arising from spilled, leaking or burning materials. Fire and/or
salvage teams may also be able to bring additional equipment to
the ship to assist in dealing with such hazards."
(MSC.1/Circ.1183, paragraph 2.1.1)
12. The overarching
MIRG FRS strategy for this scenario at sea, is to stabilise and
contain the incident sufficiently to prevent a mass evacuation
until the casualty vessel can be brought alongside and sufficient
resources deployed to conclude the incident. This strategy fully
supports and aligns with the ethos of the IMO MSC guidance.
13. It is well-documented
that the masters of ships dealing with fires at sea very much
welcome such support, and especially professional firefighting
advice. The alternative may be a complete or precautionary partial
evacuation of the ship at sea, exposing passengers and non-essential
crew to very significant additional risks.
14. Two approaches
are utilised to provide the assessment of risk undertaken by BMT
Isis Ltd. The first which is based on a dataset provided by the
Marine Accident Investigation Branch (MAIB) considers fires that
had the potential to cause multiple fatalities within UK territorial
15. The report
identifies that the overall frequency of these potential incidents
is approximately two per year for the whole of the UK and that
"this approach identifies that a response capability is
required for all of the UK coastline".
16. The second
approach identifies fires that have actually occurred in Europe
within the last 50 years and have resulted in multiple fatalities
involving passengers. The report estimates that the probability
of such an incident in UK waters is 1 in 100 per year and concludes
"that the second approach corroborates the finding that a
response is required".
17. Both of
these approaches determine that the potential risk exceeds the
tolerable/intolerable risk threshold identified within the report
as the probability of an incident being greater than 1 in 1000
18. The report
authors identify that the Civil Contingencies Act 2004 Guidance
on Emergency Preparedness considers a "Significant"
transport accident scenario as one in which the accident involves
10 fatalities and further that the guidance "states that
an incident with a likelihood of 1 in 200 over a five year period
(equivalent to 1 in 1,000 per year where the incident rate is
constant) is described with a likelihood of 'Level 3Unlikely'".
19. The Guidance
also proposes that for the reasonable worst case scenario, with
a likelihood of "Unlikely" and an impact of "Significant"
since it is a transport accident that would result in more than
10 fatalities, the risk classification of this scenario is "Very
20. The guidance
defines "Very High Risk" as:
"These are classed as primary or critical
risks requiring immediate attention. They may have a high or low
likelihood of occurrence, but their potential consequences are
such that they must be treated as a high priority. This may mean
that strategies should be developed to reduce or eliminate the
risks, but also that mitigation in the form of (multi-agency)
planning, exercising and training for these hazards should be
put in place and the risk monitored on a regular frequency. Consideration
should be given to planning being specific to the risk rather
21. The Appendix provides a breakdown of passenger
vessel fires that have occurred within International, European
and UK waters since 1963. These incidents substantiate the worst
case scenario as above, in some examples with a significant loss
22. Whilst UK waters have not yet experienced
a passenger vessel fire culminating in loss of life there are
several recorded incidents where this potential existed. The first
deployment of MIRG (May 2006) to the Cruise Ship Calypso occurred
within one month of its introduction. The vessel had 708 people
on board and requested assistance to deal with a serious engine
room fire. Her Master considered a partial evacuation of the ship,
at night, in the Dover Strait Traffic Separation Scheme as a precaution.
Deployment of the MIRG helped avoid this scenario and the resultant
risks to the safety of the passengers.
23. Unfortunately within European waters there
have been incidents involving fire that have resulted in a significant
loss of life.
- The LAKONIA 128 fatalities.
- The SCANDINAVIAN STAR 159 fatalities.
- The MOBY PRINCE 143 fatalities.
24. Anecdotal evidence also supports the BMT
Isis Ltd assessment of risk. The MCA "Consultation on Proposals
for Modernising the Coastguard document (2010), considers that
'our seas are becoming more congested', 'ships are getting
larger' whilst the 'coastline is getting busier'."
25. There is increasing demand and scale within
the Cruise Liner industry which represents one of the largest
growing sectors of the holiday market (Department for Transport
26. The expansion of green energy sites at sea
and the associated numbers of people that will be located within
these areas will provide for significant future life risk.
27. It is envisaged that there will be a significant
increase in passenger numbers arriving in UK ports in the lead
up to the London 2012 Olympic Games. Any incident involving fire
on a passenger vessel will provide for high profile international
interest, whilst presenting an increased risk to Coalition Government
priorities and DfT business objectives "contribute to
a successful 2012 Olympics" (Business Plan 2011-15).
28. CFOA is a current member of the Association
of Chief Police Officer's Maritime Advisory Group (MAG), a national,
multi agency community that has been established to assist in
the development of measures to ensure the effective co-ordination
of the national response to a Maritime Terrorist incident within
UK waters and surrounding seas. Within this context the group
has considered if MIRG would have any capability to assist in
a terrorist marine incident, either along the lines of London
7/7 or in a post Chemical Biological Radiological Nuclear (CBRN)
scenario. Preliminary work has identified that subject to a "permissive
environment" having been established, MIRG could provide
a capability if required to assist in resolving the consequences
arising from terrorist activity on a ship.
29. The DfT, Transport Spending Review Press
Notice (20/10/10) Annex F, announced that a review of MIRG would
be undertaken and that "since the MIRG teams began operating
in 2006 they have not been involved in any significant incidents.
All ships' crews are trained in basic fire fighting techniques
and there is little evidence that MIRG has changed the outcome
of ship fires".
30. Fire fighting training that ships crews undertake
is regulated by The Standards of Training, Certification &
Watch keeping (STCW) Convention. All mariners are initially required
to undertake basic training in fire prevention and fire fighting,
a two day course, and may subsequently undertake advanced training
in fire fighting, a four day course, subject to requirements
set out in Section A-VI/3 of the STCW Code.
31. Within the convention there is no requirement
for any revalidation and /or additional fire fighting training.
32. The MIRG have attended six significant incidents
at sea since its inception. In each case there has been the potential
for loss of life and the Ship's Master had requested assistance
in the form of additional fire fighting resources to augment the
33. Each MIRG deployment has provided the Master
with an additional, highly trained and professional resource that
can assist them with both the strategic and tactical dimensions
of a fire incident on board their vessel.
34. The MAIB investigation (Report No 8/2007)
into the Calypso incident above reported that the MIRG "provided
much needed support and advice to the ships master and to the
35. The Marine Safety Act 2003 provides for powers
of intervention and directions to the Secretary of States Representative
(SOSREP) inclusive of powers in relation to places of refuge.
In determining a suitable place of refuge a risk assessment must
be carried out by the SOSREP to carefully consider both the economic
and environmental impact to the UK if the incident deteriorates.
36. As the use of places of refuge could encounter
local opposition and involve political decisions the UK Government
has recognised that a properly argued technical case, based on
a clear description of the state of the casualty, would be of
great value in any decision making which may take place.
37. The most recent MIRG deployment (October
2010) was to the large fish factory vessel ATHENA from which 81
persons evacuated whilst the crew remained to contain the fire.
MIRG was deployed to this incident at the request of the SOSREP
to provide an at sea assessment on the condition of the ship and
to assist in the containment of the fire. MIRG also provided an
invaluable link between the vessel and the Local Authority FRS
within whose area of responsibility the vessel would ultimately
38. The Review report identifies that MIRG currently
provides a professional, specific and specialised response to
incidents at sea. A commercial replacement of the MIRG would be
expensive and that "The existing form of provision (MIRG)
has inherent cost advantages because all the basic training and
non-MIRG Firefighter training time is funded elsewhere".
39. It considers that the most appropriate option
identified for future provision of an at sea response to fire,
chemical hazards and industrial accidents is a continuation of
the MIRG model but with a realignment to match the resources to
the identified risk.
40. Cognisant of the Review findings the current
MIRG provision has been assessed with a view to realigning to
the identified risk. It is considered that UK MIRG resilience
arrangements could continue to be maintained within nine FRS's
with a reduction in the cadre of specialist Fire-fighters necessary
41. The MCA currently provide £600k direct
funding to support the MIRG provision, whilst the FRS collectively
provides an equal amount. The annual direct funding requirement
from the MCA necessary to maintain the revised arrangements would
be in the order of £340k, a significant reduction on the
previous figure of £600k.
42. The previous evidence submitted by CFOA to
the TCS inquiry provided the background to the "Sea of Change"
project and the subsequent introduction of the MIRG. An increasing
decline in UK resilience for dealing with fires at sea and the
fallout from a fire on board a vessel in the North Sea in 2001,
provided the catalyst for the "Sea of Change" project,
which at the request of the Secretary of State for Transport was
commenced by the MCA in partnership with CFOA in January 2003.
In April 2006, 3 years after the commencement of the project,
the Secretary of State for Transport formally launched the implementation
43. The independent assessment of risk conducted
by BMT Isis Ltd considers that there is a "Very High Risk"
of a "Significant" incident involving a passenger
vessel at sea within the territorial waters of the UK. "The
risk assessment has confirmed that a response is needed
around most of the UK, to attend and contain vessel fires with
the purpose of preventing loss of life". That
"Eliminating the provision is not considered an option"
in the context of the identified risk.
44. Whilst there is no statutory duty on the
MCA or FRS to make provision for a response to fires at sea, the
current financial support provided by the MCA and equally matched
by the FRS, ensures an integrated, interagency national strategy
for dealing with incidents in the maritime environment.
45. The independent review commissioned by the
MCA concludes that MIRG provides a cost effective and timely emergency
response to incidents Involving Fire, Chemical Hazards and Industrial
Accidents at Sea. "Any commercial equivalent would be
expensive and unlikely to constitute an emergency service".
46. A revised cost effective MIRG model has been
proposed that will maintain the current UK resilience to deploy
FRS assets to incidents at sea.
47. Without the provision of the necessary funding
to maintain the role of the MIRG it will quickly fall into decline
and become vulnerable to similar issues which first initiated
the formation of the "Sea of Change" project.
48. There will be no provision for the UK to
deploy FRS resources to vessels at sea within significant areas
of the United Kingdom Search and Rescue Region (UKSRR), this within
the context of the Review findings and an escalating risk profile.
49. This issue is entering a critical phase in
respect of funding. Individual MIRG FRS's are currently in the
process of presenting papers to their respective Fire Authorities
to determine the continuation or withdrawal of their involvement
in MIRG. Early indications are that the majority, if not all,
FRS would not be able to continue to provide this capability if
the funding currently provided by the MCA is withdrawn.
50. MIRG has an important role to play in the
safety of passengers travelling by sea off the UK coastline and
this has been recognised in the Review report. It is an extremely
cost effective model that has been developed and enhanced over
a number of years and an excellent example of partnership working
across Government departments. CFOA would encourage the Transport
Select Committee to recognise the service provided by MIRG teams
across the UK and recommend its continuation through the provision
of adequate national funding.
PASSENGER VESSEL FIRESDATA REPRESENTATIVE
OF WORST CASE SCENARIO (WORLDWIDE)
||Crew at Risk||Passenger at Risk
||Total at Risk||Total Injuries
||Al Salam Petrarca 90||68
||Catalyn - D||-||237
||Queen of the West||53
||Laut Teduh 2||-||477
CS = Cruise Ship
RO = Ro-Ro/Passenger Vessel